SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Metal Furniture Coating (40 CFR Part 60, Subpart EE) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Metal Furniture Coating (40 CFR Part 60, Subpart EE) (Renewal), 

EPA ICR Number 0649.11, OMB Control Number 2060-0106

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Metal Furniture Coating were 

proposed on November 28, 1980, and promulgated on October 29, 1982. These regulations 

apply to each metal furniture surface coating operation in which organic coatings are applied 

(greater than 3,842 liters of coating per year), commencing construction, modification or 

reconstruction after November 28, 1980. This information is being collected to assure 

compliance with 40 CFR part 60, subpart EE.

In general, all NSPS standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in 

the operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NSPS. 

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least two years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. 

In the event that there is no such delegated authority, the reports are sent directly to the regional 

offices of the U.S. Environmental Protection Agency (EPA).

 Based on our consultations with industry representatives, there is an average of one

affected facility at each plant site and that each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

Over the next three years, an average of 400 respondents per year will be subject to the 

standard, and no additional respondent per year will become subject to the standard. 

The Office of Management and Budget (OMB) approved the currently active Information 

Collection Request (ICR) without any “Terms of Clearance.”

The “Affected Public” is private sector businesses that perform surface coating of metal 

furniture products. The burden to the “Affected Public” may be found below in Table 1: Annual 

Respondent Burden and Cost – NSPS for Metal Furniture Coating (40 CFR Part 60, Subpart EE)
2

(Renewal). The burden to the “Federal Government” is attributed entirely to work performed 

by either Federal employees or government contractors; this burden is found below in Table 2: 

Average Annual EPA Burden and Cost – NSPS for Metal Furniture Coating (40 CFR Part 60, 

Subpart EE) (Renewal).

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, 

to establish standards of performance for new stationary sources that reflect: 

. . . application of the best technological system of continuous 

emissions reduction which (taking into consideration the cost of 

achieving such emissions reduction, or any non-air quality health 

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated. 

Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated 

technology (BDT). Section 111 also requires that the Administrator review and, 

if appropriate, revise such standards every four years.

In the Administrator's judgment, hazard air pollutant emissions from metal furniture 

coating cause or contribute to air pollution that may reasonably be anticipated to endanger public 

health or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR 

part 60, subpart EE.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with 

the applicable regulations which where promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. Continuous emission monitors are used to 

ensure compliance with the standard at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor. 

The notifications required in the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated and leaks are being detected and repaired and the standard are being met. 
3

The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under (40 CFR part 60, subpart

EE).

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, 

duplication does not exist.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (77 FR 47631) on August 9, 2012. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

 

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard, is the Online Tracking Information System (OTIS) which is operated 

and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of all compliance data. The growth rate for the industry is based on 

our consultations with the Agency’s internal industry experts. 

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed and the standard 

has been previously reviewed to determine the minimum information needed for compliance 

purposes. In developing this ICR, we contacted: 1) Chromcraft Furniture, at (866) 777-1951;

and 2) Winston Furniture Company, Incorporated, at (205) 486-9211.

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received.
4

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR part 1320, section 1320.5.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are metal furniture 

coating facilities. The United States Standard Industrial Classification (SIC) codes for the 

respondents affected by the standards, which corresponds to the North American Industry 

Classification System (NAICS) codes, are listed below for metal furniture coating facilities.

Standard (40 CFR Part 60, Subpart EE) SIC Codes NAICS Codes

Metal Household Furniture Manufacturing 2514 337124

Office Furniture (except Wood) Manufacturing 2522 337214

Institutional Furniture Manufacturing 2531, 2542 337127

Showcase, Partition, Shelving, and Locker 

Manufacturing 2542, 2514 337215

 
5

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by NSPS for Metal 

Furniture Coating (40 CFR Part 60, Subpart EE). 

A source must make the following reports:

Notifications

Notification of construction/reconstruction 60.7(a)(1)

Notification of initial performance test 60.8(d)

Notification of actual startup. 60.7(a)(3)

Notification of a physical or operational change. 60.7(a)(4)

Reports

Actual startup 60.7(a)(3)

Initial performance test results 60.8(a)

Demonstration of continuous monitoring system 60.7(a)(5)

Semiannual report 60.7(d)

Excess emissions report 60.7(c), 60.315(b)

A source must keep the following records:

Recordkeeping

Startups, shutdowns, malfunctions, periods where the continuous 

monitoring system is inoperative. 60.7(b)

Records are required to be retained for two years at the facility. 60.315(d)

Maintain a file of all measurements including the monitoring device, 

and performance testing measurements, and monitoring device 

calibrations, checks, adjustments and maintenance performed on these 

devices.

60.7(e)

Maintain a file of all data and calculations used to determine VOC 

emissions. 60.315(d)

Maintain daily records of incinerator combustion temperature, or 

amounts of solvent recovered. 60.315(d)
6

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not 

widely used. At this time, it is estimated that approximately 10 percent of the respondents use 

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for temperature for incinerator.

Perform initial performance test, Reference Method 24 test, and repeat performance tests if 

necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

Adjust the existing ways to comply with any previously applicable instructions and 

requirements.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way e.g., continuous parameter monitoring system. Although personnel at 

the source still need to evaluate the data, this type of monitoring equipment has significantly 

reduced the burden associated with monitoring and recordkeeping. 

5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, 
7

storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS). 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply 

with the emission standard. Data and records maintained by the respondents are tabulated and 

published for use in compliance and enforcement programs. The semiannual reports are used for 

problem identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses the OTIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for two

years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown in below Table 1: Annual Respondent Burden and Cost – NSPS for Metal Furniture 
8

Coating (40 CFR Part 60, Subpart EE) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 56,074 (Total Labor Hours from Table 1 below). 

These hours are based on Agency studies and background documents from the development of 

the regulation, Agency knowledge and experience with the NSPS program, the previously 

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $121.44 ($57.83 + 110%) 

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 

2012, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the 

subject standard are both labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring. The capital/startup costs are one time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitor(s) and other costs such as photocopying and postage.
9

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

Temperature 4,400 0 $0 $2,100 400 $840,000

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $840,000. This is 

the total of column G. 

The average annual cost for capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $840,000. These are 

recordkeeping costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$99,503. 

This cost is based on the average hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2012 General Schedule,

which excludes locality, rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NSPS for Metal 

Furniture Coating (40 CFR Part 60, Subpart EE) (Renewal).

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately

400 existing respondents will be subject to the standard. It is estimated that no additional
10

respondent per year will become subject. The overall average number of respondents, as shown 

in the table below is 400 per year.

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year (A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 400 0 0 400

2 0 400 0 0 400

3 0 400 0 0 400

Average 0 400 0 0 400

1

New respondents include sources with constructed, reconstructed and modified affected facilities.

.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 400.

The total number of annual responses per year is calculated using the following table: 

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Notification of 

construction/reconstruction 0 1 0 0

Notification of performance test 0 1.2 0 0

Notification of actual startup 0 1 0 0

Report of performance test 0 1.2 0 0

Semiannual report 400 2 0 800

Excess emissions report 80 2 0 160

Total 960

The number of Total Annual Responses is 960.

The total annual labor costs are $5,429,572. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NSPS for Metal Furniture 

Coating (40 CFR Part 60, Subpart EE) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables
11

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 56,074 at a cost of $5,429,572. Details regarding these 

estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for 

Metal Furniture Coating (40 CFR Part 60, Subpart EE) (Renewal). 

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 58 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $840,000. 

The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and 

Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 

2,208 labor hours at a cost of $99,503. See below Table 2: Average Annual EPA Burden and 

Cost – NSPS for Metal Furniture Coating (40 CFR Part 60, Subpart EE) (Renewal).

6(f) Reasons for Change in Burden

There is no change in the burden hours in this ICR compared to the previous ICR. This is 

due to two considerations: 1) the regulations have not changed over the past three years and are 

not anticipated to change over the next three years; and 2) the growth rate for the industry is very

low, negative or non-existent, so there is no significant change in the overall burden. 

There is an increase in costs for both the respondents and the Agency from the most 

recently approved ICR. The increase in burden cost is due to an increase in labor rates. This 

ICR uses updated labor rates from the Bureau of Labor Statistics to calculate burden costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 58 hours per response. “Burden” means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, 

and verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 
12

the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-2012-0530. An electronic version of the public docket is 

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2012-0530 and OMB Control Number 2060-0106 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
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Table 1: Annual Respondent Burden and Cost – NSPS for Metal Furniture Coating (40 CFR Part 60, Subpart EE) (Renewal)

BURDEN ITEM

Hours/

Occurrence

(A)

Occurrences/ 

Year 

(B)

Hours/Year 

(C=AxB)

(C)

Respondents/

Year b

(D)

Technical

Person Hours

(E=CxD)

Managerial

Person 

Hours

(Ex0.05)

Clerical 

Person Hours

(Ex0.10)

Total 

Costs/Year a 

(F)

1. APPLICATIONS N/A N/A N/A N/A N/A N/A N/A N/A

2. SURVEY AND STUDIES N/A N/A N/A N/A N/A N/A N/A N/A

3. REPORTING REQUIREMENTS

a. Read Instructions 1 1 1 0 0 0 $0 $0

b. Required Activities

Initial Performance Tests 60 1 60 0 0 0 0 $0

Repeat Performance Tests 60 0.2 12 0 0 0 0 $0

c. Gather Existing Information ------------------------Included in 3b----------------------------

d. Write Report

Notification of 

Construction/

Reconstruction

2 1 2 0 0 0 0 $0

Notification of Initial 

Performance Test 2 1 2 0 0 0 0 $0

Notification of Actual 

Startup 2 1 2 0 0 0 0 $0

Report of Performance Test ------------------------Included in 3b----------------------------

Semiannual Report c8 2 16 400 6,400 320 640 $712,659.20 

Excess Emissions Report d16 2 32 80 2,560 128 256 $285,063.68 

Subtotal for Reporting Requirements 10,304 $997,723 

4. RECORDKEEPING 

REQUIREMENTS

a. Read Instructions ------------------------Included in 3a----------------------------

b. Plan Activities ------------------------Included in 3b----------------------------

c. Implement Activities (Monthly 

Performance Test) e 1 12 12 400 4,800 240 480 $534,494.40 

d. Develop Record System N/A N/A N/A N/A N/A N/A N/A N/A

Records of Operating 

Parameter f 0.25 350 87.5 400 35,000 1,750 3,500 $3,897,355.00 

Subtotal for Recordkeeping 

Requirements 45,770 $4,431,849 
14

BURDEN ITEM

Hours/

Occurrence

(A)

Occurrences/ 

Year 

(B)

Hours/Year 

(C=AxB)

(C)

Respondents/

Year b

(D)

Technical

Person Hours

(E=CxD)

Managerial

Person 

Hours

(Ex0.05)

Clerical 

Person Hours

(Ex0.10)

Total 

Costs/Year a 

(F)

TOTAL LABOR BURDEN AND COST 56,074 $5,429,572 

Assumptions:

a This ICR uses the following labor rates: $121.44 per hour for Executive, Administrative, and Managerial labor; $100.23 per hour for Technical labor, and $50.51 

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “Table 2. Civilian Workers, by 

Occupational and Industry group.” The rates are from “column 1, Total Compensation. “ The rates have been increased by 110% to account for the benefit

packages available to those employed by private industry.

 b We have assumed that there are approximately 400 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three

 years. 

 c We have assumed that each respondent will take eight hours twice per year to complete the semiannual report.

 d We have assumed that 20 percent of respondent will each take 16 hours twice per year to complete the excess emissions reports. 

 e We have assumed that each respondent will take one hour once per year to record monthly performance test.

 f We have assumed that each respondent will have 0.25 hours 350 days per year to keep record of operating parameters.
15

Table 2: Average Annual EPA Burden and Cost – NSPS for Metal Furniture Coating (40 CFR Part 60, Subpart EE) (Renewal)

REPORTING/RECORDKEEPING 

REQUIREMENT

EPA 

Hours/Occurrence 

(A)

Occurrences

/Plant/Year 

(B)

EPA Hours/ 

Year 

(C=A*B)

Plants/Year

(D)

Technical 

Person Hours

(E=CxD)

Managerial 

Person Hours

(Ex0.05)

Clerical Person 

Hours

(Ex0.10)

Total 

Costs/Year a

(F)

INITIAL PERFORMANCE TESTS

New Plant 24 1 24 0 0 0 0 $0 

REPEAT PERFORMANCE TEST

New Plant 24 0.2 4.8 0 0 0 0 $0 

REPORT REVIEW

New Plants

Notification of Construction 2 1 2 0 0 0 0 $0 

Notification of Initial 

Startup 0.5 1 0.5 0 0 0 0 $0 

Notification of Actual 

Startup 0.5 1 0.5 0 0 0 0 $0 

Notification of Initial Test 0.5 1.2 0.6 0 0 0 0 $0 

Review Test Results 8 1.2 9.6 0 0 0 0 $0 

Existing Plants

Semiannual Reports 2 2 4 400 1,600 80 160 $82,919.20 

Excess Emissions Reports 2 2 4 80 320 16 32 $16,583.84 

TOTAL BURDEN AND COST 2,208 $99,503

Assumptions:

a This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $62.27 

(GS-13, Step 5, $38.92 x 1.6), Technical rate of $46.21 (GS-12, Step 1, $28.88 x 1.6), and Clerical rate of $25.01 (GS-6, Step 3, $15.63 x 1.6). These rates are from the Office of 

Personnel Management (OPM) 2012 General Schedule which excludes locality rates of pay.

 b We have assumed that it will take two hours twice per year to review the semiannual report.

 c We have assumed that 20 percent of existing plants will each take two hours twice per year to review the excess emissions reports.